Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Circumstantial evidence of routed bank credits, cash deposits before registration, and unexplained transferors' funds was sufficient to establish a prima facie benami transaction in immovable properties. The appellants failed to show an independent source of consideration for the purchases, and their disclosed income was inadequate to fund the acquisitions. Statements under the PMLA and surrounding material supported accommodation entries and cash repayment arrangements. Even without reliance on the alleged beneficial owner's role, the benami case survived because the benamidars themselves could not explain the source of funds. The provisional attachment was therefore sustained and the appeals were dismissed.
Circumstantial evidence of routed bank credits, cash deposits before registration, and unexplained transferors' funds was sufficient to establish a prima facie benami transaction in immovable properties. The appellants failed to show an independent source of consideration for the purchases, and their disclosed income was inadequate to fund the acquisitions. Statements under the PMLA and surrounding material supported accommodation entries and cash repayment arrangements. Even without reliance on the alleged beneficial owner's role, the benami case survived because the benamidars themselves could not explain the source of funds. The provisional attachment was therefore sustained and the appeals were dismissed.
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